GUIDELINE SERIES
OAQPS NO. 1.2-011
DRAFT
GUIDELINES FOR DETERMINING THE NEED FOR
PLAN REVISIONS TO THE CONTROL STRATEGY
PORTION OF THE APPROVED
STATE IMPLEMENTATION PLAN
3OC
US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina
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OAQPS 1.2-011
GUIDELINES FOR DETERMINING THE NEED FOR
PLAN REVISIONS TO THE CONTROL STRATEGY
PORTION OF THE APPROVED
STATE IMPLEMENTATION PLAN
DRAFT
Analysis and Reports Section
Standards Implementation Branch
Control Programs Development Division
Office of Air Quality
.Planning and Standards
November 30, 1973
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TABLE OF CONTENTS
I. Introduction 1
II. Responsibilities in Implementing Plan Revisions. ... 3
III. Procedures for Determining Whether a SIP/Control
Strategy Needs to be Revised 5
A. Identification of Problem Air Quality Control
Regions 5
B. Evaluation of Data 7
C. Analysis of Control Strategy 10
D. Reporting of Results 13
IV. Procedures for Requiring Plan Revisions. . v 14
A. Plan Revision Documentation. 14
B. Notification and Concurrence 15
C. Notification of State 15
D. Plan Submittal 17
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I. Introduction
Section 110(a)(2)(H) of the Clean Air Act, as amended requires that
State Implementation Plans (SIP's) "provide for revision, after public
hearings, of such plan (1) from time to time as may be necessary to take
account of revisions of such national primary or secondary ambient air
quality standard or (2) the availability of improved or more expeditious
methods of achieving such primary or secondary standard; or (3) whenever
the Administrator finds on the basis of information available to him
that the plan is substantially inadequate to achieve the national ambient
air quality primary or secondary standard which it implements."
While the Act specifically identifies three (3) reasons why SIP's can
and must be revised, this guideline deals mainly with plan revisions to
the control strategy portion of the SI? which are deemed necessary on the
basis of information available to the Agency which indicates the approved
SIP/control strategy is inadequate to attain the national standard it
implements. While the reasons for requesting a revision may be different,
the administrativa procedures for requesting a revision under each of the
three cases is the same.
EPA must exercise good judgement in determining whether the control
strategy portion of an approved SIP is inadequate to achieve national
standards on a timely basis. It should be the Agency's policy to request
such plan revisions only where they are clearly necessary. Frequent
revisions, particularly where they affect emission control requirements,
are undesirable in that they confront source owners with a "moving target."
In an attempt to assist in identifying those Regions that may need plan
revision, the Standards Implementation Branch (SIB) of the Control Programs
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Development Division, Office of Air Quality Planning and Standards, has
developed a PLAN REVISION MANAGEMENT SYSTEM (PRMS) which compares actual
measured air quality levels, submitted by States as part of their quarterly
reports, with projected emission reductions required by the adopted emission
limitations contained in the approved SIP. The system is capable of moni-
toring the progress in each AQCR and when ambient air quality levels do not
follow the anticipated reductions, the region will be flagged as a "potential
problem region." Further investigation by regional personnel will be necessary
prior to the determination of whether a plan revision is needed.
The majority of the information that will be needed to formulate the
decision as to whether the control strategy is inadequate to achieve
the national standards will be obtained from the quarterly and semiannual
reports (40 CFR 51.7, Report, August 3, 1973). Of course, other informa-
tion such as the Quarterly Trends Report, daily contacts with State and
local agencies, compliance information (see enclosure 1), etc., should
also be used in the determination. Air quality data will be the key
indicator of a "potential problem region," as measured air quality will
be the real indicator of attainment of the NAAQS. However, emission
data, enforcement and compliance information, etc. must be reviewed to
determine the adequacy of the control strategy to attain the national
standard in relation to the measured air quality levels. \
j
This guideline sets forth (1) the procedures for determining when
a revision to the control strategy portion of the SIP is necessary (2)
the procedures for notifying the State that a plan revision is necessary
and (3) the responsibilities of headquarters and regional personnel in
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implementing the:e procedures.
II. Responsibilities in Implementing Plan Revisions
In cases where revisions to the control strategy are necessary
because new information indicates that the approved control strategy
is inadequate to attain the national standards, the Regional Office
will be primarily responsible to review available information and
recommend any action, if appropriate, to call for a plan revision.
Recently, in response to a request by the Assistant Administrator
for OAWP, the Administrator delegated his authority to request a plan
revision to the Regional Administrators'through EPA Order 1270.5 (see
enclosure). In cases where the requested revision would significantly
affect emission control regulations, or the enforcement thereof,
Regional Administrators should obtain the concurrence of the Deputy
Assistant Administrator for Air Quality Planning and Standards and the
Deputy Assistant Administrator for General Enforcement prior to request-
ing that the State make the revisions. Further, where the requested
revision would have significant national policy implications or would
establish a significant precedent (the first time a substantial type
of action is taken anywhere), the above Deputy Assistant Administrators'
concurrences should be requested. Insofar as other revisions are concerned,
Regional Administrators should simply notify the above Deputy Assistant
Administrators of requests trade.
OAWP/OAQPS will provide overall assistance to the Regions in this
area. A Plan Revision Management System is in operation which will provide
a review of the air quality data received from each State and local agency
and identify those Regions where it appears adequate progress is not
being made in attaining the air quality standards as provided in the
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implementation of the SIP. In addition, OAQPS wi.ll publish the Quarterly
Trend Reports, Quarterly Air Quality Summary Statistics and the Annual
National Emission Report. These reports will serve to assist the
Regional Offices; as the Regional Offices will have the primary responsi-
bility for determining whether a plan revision is needed.
Once tne plan revision has been submitted by the State, the Regional
Offices (as outlined in the September 14, 1972, Sansom/Quarles memo of
understanding, as revised in 1.2-005 (revised) of the OAQPS Guideline
Series) are further responsible to review, to recommend approval/dis-
approval and promulgation and to prepare the Federal Register package
associated with any measures which have been determined to be necessary
to assure that the national standards will be achieved.
Headquarters (OAWP/OAQPS and OEGC/DSSE) will provide technical and
policy assistance to assure national uniformity on various issues insofar
as appropriate. Headquarters will also have the responsibility to review
and to concur or nonconcur with the recommended action for each revision.
The Agency responsibilities are somewhat different in those cases
where plan revisions are necessary to take account of new or revised
national standards. In this case, OAWP has the primary responsibility
of preparing and publishing in the federal Register (1) the new or
revised national standards and (2) specific guidelines en what actions
States need to take to develop, adopt and submit an approvable plan to
implement the new or revised standard. In general, all States will be
required to subnit a plan for a new national standard or will be required
to revise their existing SIP's to consider a revised national standard.
After OAWP has published guidelines for the dc-velopmont of approved SIP's,
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the Regional Offices are then responsible to assist States in the
development of SIP's etc.
In situations where the SIP regulations (40 CFR Part 51) are
modified in such a way as to affect the control strategy requirements
(such as the recent action in relation to maintenance of standards
(40 CFR 51.12, June 18, 1973) and the pending action in relation to
tall stacks) OAWP and Regional Office responsibilities are identical
to those described for a new or revised standard.
III. Procedures for Determining Whether a SIP./Control Strategy Meeds to Be
Revised
A. Identification of problem air quality control regions
It is difficult to develop comprehensive guidance on exactly
how to detemine whether a control strategy will need to be revised.
While there may be a few situations where it is obvious that a plan
revision is necessary, in general it will be a difficult task to
determine that a plan is inadequate to attain the standards prior to
the established attainment date. The problem is to determine whether
AQCR's are progressing satisfactorily in relation to the emission limi-
tations contained within the SIP. To this end, a Plan Revision Manage-
ment System (PRMS) was developed to track the progress being made by
States in implementing their SIP. PR/MS provides a means for effectively
combining information contained in SAROAD (air quality) NEDS (source
emissions), and CDS (enforcement and compliance information) to compare
measured progress against expected progress.
This system is designed to monitor the progress of actual air
quality levels, obtained from the quarterly reports, in relation to the
anticipated air quality reductions which should occur as a result of
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compliance with approved emission limitations. If the difference between
the observed and projected air quality levels exceed certain specified
limits, then the site is "flagged" as a "potential problem." A number of
flagging levels or tolerance limits are incorporated in the system to
indicate that the site either has acceptable progress or is having a minor,
major or significant problem toward attainment of the NAAQS. The tolerance
limits were developed through the application of statistical quality control
techniques which allow for the many variables associated with measured air
quality concentrations. (See Figure 1)
Once a "potential problem region" is identified, OAQPS will notify
the appropriate Regional Office. This will be done on a semiannual basis.
The Regional Office will be responsible for investigation and further assess-
ment of the problem. The Regional Office should also report their findings
to OAQPS indicating the action they have taken or plan to take.
. While the PRMS will provide a mechanism to identify "potential problem
regions" from an analytical point of view, the Regional Offices should be
more intimately aware of the status of Regions within their States. Thus,
the Regional Offices may be aware of other AQCR's not currently being
analyzed by the PRMS which should be reviewed to determine if the plan is
adequate to attain the NAAQS by the specified data for attainment.
Currently, there are 17 AQCR's contained in the PRMS. An additional
50 Regions will be included in the system by January 1974. The additional
50 Regions that were selected for analysis were based on recommendations of
the Regional Offices as to those AQCR's which should be reviewed to insure
that adequate progress is being made toward attainment of the standards.
By mid-1974, 50 more AQCR's are scheduled to be included in the PRMS. Thus,
by July 1974, 117 Regions will be analyzed. The Regional Offices should
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Figure 1
PLAN REVISION MANAGEMENT SYSTEM
Particulate Matter
Emissions
(1000 tons/year) 150
100
50
1970 1971 1972 1973 1974 1975 1976 1977
Air quality
(yg/m3)
150
100
50
0
Tolerance limits
Projected air
quality
1970 1971 1972 1973 1974 1975 1976 1977
Calendar Year
"Measured air quality
Step
#1 Calculation of emission reduction (NEDS, Emission Regulations)
#2 Review of compliance dates (SIP, CDS, Emission Regulations)
#3 Projection of air quality
#4 Establishment of tolerance limits or boundaries
#5 Measured air quality trend (SAROAPN
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indicate to OAQPS those AQCR's that they believe should be reviewed to
determine the possible need for plan revisions.
It is understood that air quality levels throughout an AQCR are
highly variable and that each monitoring site within the region must
have levels at or below the national standards by the specified date
for attainment to be in compliance with the Act. The PRMS analyzes all
monitoring sites within SAROAD for the particular AQCR in question to
determine if adequate progress is being made. Thus, the system is capable
of defining the problem on a much smaller scale than the entire AQCR.
While most of the'region may be showing adequate progress, a few sites,
located in areas of maximum concentration, may be deviating from the
desired air quality levels. Review of these sites will allow the Agency
to take a much closer look at the real problem areas. Because the R.O.
may only be required to review a very few problem sites, more effort can
be placed upon those areas within an AQCR which appear to-.be having the
most difficulty 'in attaining the standards. It is believed'at ^his time
that it will not be necessary in most cases to require a major plan
revision for an entire AQCR. The revision or additional action can be
tailored to a minimum number of sources to give the maximum amount of
benefit toward attainment of the standards. Thus, a review to determine
the adequacy of the progress for a region should be done on a site by site
basis.
B. Evaluation of Data
The review of problem monitoring sites should include three basic
items. Is the data valid? What were the meteorological conditions during
the reporting period? Is the control strategy for the region adequate to
correct the problem at this site?
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The validity of the air quality data is the major item in the
review of potential problem sites. Monitoring and Data Analysis Division,
OAQPS is preparing several guidelines to assist in the validation of air
quality data. (See enclosure #3)
While EPA should generally be confident of the validity of the air
quality data submitted by State and local agencies, it is also necessary
to review the validity of specifid data especially those data which indi-
cate the need for plan revision. The Regional Office should refer to the
guidelines mentioned above for the specific items that must be reviewed
to verify the data. However, basically these steps should include:
a. Discussion with the State or local agency to verify their
confidence in the submitted data.
b. Determination that the State or local agency laboratory or
quality control procedures are adequate.
c. Determination that the sampling instrument that was used to
measure the data was calibrated and operating properly.
d. Review the strip chart or other record of the measurement to
verify the reported values.
e. Determine if the sampling method by which the data were measured
is reliable and in accordance with the specified reference method
or equivalent.
f. In certain cases, it may be necessary to visit the monitoring site
to determine its representativeness. Does it meet EPA criteria
for location of ambient monitors? Are surrounding structures or
buildings causing unusual air flow patterns near the sampler? Is
the sampler influenced by emissions from the chimney or incinerator
of the building on which the sampler is located, or is the sampler
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on a building surrounded by a heavily used unpaved parking lot?
In summary, is the data collected by the site representative of
air quality levels and should the data collected at the site- be
used as a basis for developing a control strategy?
The last item in data validation is very important. All problem
sites should be reviewed in detail. . It is suggested that each problem
site be visited to determine its representativeness and to see what local
sources, if any, may be causing the major impact upon a particular receptor.
If after a review of the above items it is determined that the air
quality values are valid then a review of the meteorological conditions
should be conducted. If the frequency and duration of inversions and
stagnations were unusually high, air quality could be higher than normal.
Unusually warm or cold weather will result in a change in fuel use which
may increase ambient levels above normal. Snow or ice storms may be assoc-
iated with excessive sanding or salting of streets, and thus increase
particulate matter concentrations. Long periods of dry weather may also
.increase the parti cul ate matter concentrations. .
The review of air quality data should also attempt to identify if
high concentrations were caused by unusual, events, such as local construc-
tion or demolition activity, fires or perhaps control equipment malfunction
or shut-down which could temporarily cause abnormally high ambient concen-
trations. Data collected during abnormal situations should not be used
as a basis for requiring plan revisions. If data are determined to be
"abnormal" or invalids or that they represent unusual circumstances, such
data should be reported so that the SAROAD data bank users are properly
notified of these conditions.
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After the air quality data has been validated and the unusual meteor-
ological conditions have been investigated, the Regional Offices should
make an attempt to obtain the very latest air quality concentrations for
the site in question. Because of the lag in processing the air quality
data from quarterly reports, the SAROAD system may be as much as two
to four quarters behind the current air quality levels; therefore, the
Regional Offices are encouraged to obtain the very latest data possible
for the sites in question and submit this data to the PRMS so that an
updated analysis can be performed to assure that we have the latest data
possible upon which to base the analysis for determining adequate progress.
The PRMS system has been developed with the capability to temporarily
accept selected data independent of the SAROAD system so that the best and
most up-to-date information is available for the Regional Office review.
Attempts should be made by the Regional Offices to see that data from
those monitoring sites with potential problems receive the highest priority
by attempting to have the data from those sites reduced and submitted to
SAROAD as quickly as possible.
C. Analysis of Control Strategy
With the addition of the latest air quality data, a comparison of the
trends in air quality levels at the site in question, with the air quality
trends noted at other sites within the Region (State, city or other area
where comparable results should exist) should be made. If the increase or
decrease is significantly different than at the other sites, it would appear
that a localized problem exists.
For the purposes of this guideline, let us assume that the site in
question is out-of-line with other ambient monitors in a region. In this
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case, it is recommended that a review of the emission data and compliance
status of sources within the immediate vicinity of the site in question
(say within a 1 to 3 mile radius—particulate matter and sulfur dioxide
only, CO and oxidant would require much large area) be made. Points to
consider include:
a. Are some sources presently uncontrolled? If so, are there
control regulations with which these sources must ultimately
comply? If not, do these sources impact sufficiently on the
site to warrant a recommendation for a plan revision to require
further emission limitations on these sources?
b. If the sources reviewed in (a) have applicable regulations that
they must adhere to at some later date, is the anticipated erris-
sion reduction adequate to reduce ambient levels to below the
standard?
c. Do the sources reviewed in (a) have applicable emission limita-
tions they must presently comply with? Are the sources in
compliance with the regulations? If so, will additional emission
reductions be needed to provide for the attainment of the national
standard? If the sources are not in compliance with the emission
limitation, is the source on a compliance schedule? Should EPA/
State enforcement action be initiated against the source?
d. Have the sources in the vicinity of the site in question increased
significantly? Is a plan revision necessary to compensate for
increases in emissions? What action is needed in relation to
assuring that the State adequately considers ambient standards
prior to their providing approval to construct new sources?
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Sometime during the investigation of potential problems there should
be a review of the technique originally utilized for the AQCR to correlate
the reduction in emissions with those in air quality levels. Such an
analysis was suggested in (a) and (b) above. There are a number of approaches
available, each providing various degrees of accuracy which can provide a
relationship betv/een emission reductions and resultant ambient air quality.
The selection of the appropriate method for determining this relationship
depends upon the Regional Office resources available to address the problem.
Basically, these methods include:
a. Simple Rollback or proportional model which assumed that as emis-
sions are reduced or "rolled back" by one percent there is a
corresponding one percent reduction in ambient levels. This is a
gross method of estimating the degree of emission reduction
necessary to meet air quality goals and is by no means absolute.
Most States used this method to develop their original SIP's
because it is relatively simple and does provide a gross estimate
of the degree of a problem in a Region. The method is deficient in-
that it does not consider meteorology, spatial distribution of
sources, nor the height of emission release; three important factors
which influence ground level concentrations. It is recommended that
in determining the need for a plan revision that a more detailed
approach be utilized in defining the relationship between emission
reductions and air quality.
b. Modified Rollback procedures have been recently developed by the
Monitoring and Data Analysis Division, OAQPS. These procedures
provide a more sophisticated approach to the relationship of
emissions to air quality. This procedure considers meteorology,
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spatial distribution of sources, and the height of emission
release. The modified rollback provides a more accurate definition
of the problem but also requires mere rofined omission data arid
more nranpov/er. The procedure is applicable to an urban area
(city center) problems.
c. Diffusion Modelin? is the preferred predictive tool available in
relating .emission to air quality duta. A number of diffusion
mc'-iels (Air Quality Display ifod^l, AQDM, and t!,ie Implementation
Planning Program, IPP) are available for defining urban situa-
tions on an annual basis. Point source modsIs are also available
for single source short-term (1 hr and 24 hr) situations. Diffusion
modeling requires detailed emission, air quality and meteorological
data to mathematically simulate the: emission/air quality relation-
ship for a given region, Voile there are certain limitations which
restrict the use of diffusion nodals (lack of data} severe topo- .. •
^ I':;[••:!! C Vc i' I •:* i. i 'j\\'i ; •.. «..'w . / * '.::<: ..'.; 1.1 ,'•.> U C.'»-:,';-• jj ;Xi V i--J'-.' >.i:'o IK..}!, i:\i'.\ , •••
able approach to predict resuVLir.g ch'ibient levels caused by the
application of emission "h'mitatioiis 0,1 emission sources. Enclosure
#4 provides a list of those diffusion models which are readily
available to the Regional Office through the Tirr.e Sharing Option
(TSO) computer facility.
D. Reporting of Results
The Regional Office will be notified 30 days after the semiannual
report is due (February 15, August 15) of those potential problems and
should report on the status of their investigation within 30 days prior to
the date due for the next semiannual report. It should be noted that the
above investigation of potential problem sites may require more than just
one semiannual reporting period to complete the investigation.
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Thus, the results reported to OAQPS for inclusion into the Adminis-
trators SIP Status Report may include several different recommended
actions. These include:
1. Data determined to be invalid—work proceeding to correct and
validate data.
2. Unusual meteorological conditions existed at the time and more
recent data indicated adequate progress.
3. No action, minor problem identified and resolved.
4. No action, new projected air quality curve should be developed
to better define the trend in estimated air quality.
5. No action, pending further study—inconclusive or marginal
analysis, too early to determine if problem exists.
6. More effective implementation of new source review procedures
to restrict growth in certain areas is needed.
7. EPA/State enforcement action is necessary
8. Plan revision is needed.
Procedures on how to require a plan revision for those cases where
the need has been identified are described in Section IV.
IV. Procedures for Requi ring PI an Reyi sions .
If a revision to the control strategy is determined to be needed, the
following actions are necessary:
A. Plan Revision Documentation
The Regional Office should document the reason why the plan
revision is necessary, providing as much detail as possible on the
discovery analysis performed to determine the need for the revision
and identify, if possible, what source(s) or source categories should
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be considered under the plan revision. While it is hoped that
, the approved SIP will be adequate to attain the national standard
on a region-wide basis, it is highly likely that portions of some
AQCR's ("subregions") will need further controls to achieve the
standards. Therefore, it is proper and necessary to identify those
sources which may need to be considered when developing the plan
revision. This analysis should be discussed with the State and local
agencies involved.
B. Notification and Concurrence
Where the requested revision would significantly affect emission
control regulations, or the enforcement thereof, the Regional Offices
should obtain the concurrence of the Deputy Assistant Administrator
for Air Quality Planning and Standards and the Deputy Assistant
Administrator for General Enforcement prior to officially requesting
a plan revision by the State. Further, where the requested revision
should have significant national policy implications or would establish
a significant precedent, the above Deputy Assistant Administrators'
concurrence should be sought. In so far as other revisions are concerned,
the Regions should simply notify the above Deputy Assistant Administrators
of plan revision requests that have been made.
C. Notification of State
The Regional Offices should confer with the State and/or local
agencies involved and advise them of the need for a revision. The
Regional Administrator should officially notify the State (Governor)
that a. revision is necessary*. The notice should identify the following:
(1) Why the plan revision is necessary
*Thc issue of whether this should be done by letter or Federal Register
notice will be discussed in a separate memo rand urn. -
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(2) What appears to be necessary to correct the deficiency
i.e., what sources appear to cause the need for further
controls
(3) What other portions of the SIP must be revised as a
consequence of the control strategy revision. These may
include:
(i) Section 51.11 Legal authority-- especially if
transportation controls are deemed necessary
(ii) Section 51.15 Compliance schedules must be provided
if new control regulations are adopted. The negotiated
schedules must be submitted at the time of submittal of
new regulations. However, if the regulation is immediately
effective, then the schedules can be submitted as a plan
revision itself.
(iii) Section 51.17 Air Quality Surveillance — The
increase of ambient levels may indicate a more widespread
problem than anticipated. More ambient sampling may be
needed to define the extent of the. problem and monitor
progress.
(iv) Section 51.21 Intergovernmental cooperation -- This
section may need to be revised if the State delegates new
responsibility to other State or local agencies to carry out
portions of the plan.
(v) Section 51.20 Resources - New control regulations may
require additional resources for enforcement purposes. Such
information should be reported with the plan revision.
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(vi) Section 51.10 General requirements - The control regula-
tions submitted as part of the plan revision may indicate the
need for a change in the date of attainment of the national
standard. Plan revisions designed to attain the primary
standard which require more stringenet controls than that
which is reasonably available, and which are more restrictive
than the original SIP may justify the need for an extension of
up to two years (section 51.30). One year postponements,
40 CFR 51.32 (revised June 19, 1973) may also be utilized. It
should also be noted that plans to attain the national secondary
standard must do so within a "reasonable time."
(4) The time period for submission of the revision to the Agency
(Section 51.6(b), Revision) states that 'the plan shall be
revised within 60 days following notification by the Adminis-
trator, or by such later date prescribed by the Administrator
after consultation with the State." Since a control strategy
will need to be developed and a compliance schedule determined
and then have the regulations subjected to a public hearing
and be adopted, it appears that four to six months and perhaps
longer will be needed in most cases to revise the control strategy
portion of the plan.
(5) The plan revision must be submitted in accordance with the pro-
visions of 40 CFR 51.4, Public hearings and 51.6, Revisions.
D. Plan Submittal
Once the plan revision is submitted by the State, the Agency procedures
outlined in the Sansom/Quarles memo of understanding of September 14. 1972,
as revised by OAQPS No. 1.2-005A, of the Guideline Series govern the review
and approval process. Because of a recent court decision, however, the
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Agency must now publish, in the Federal Register, the fact that a new
or revised SIP has been subm'tted to the Agency and that the public has
30 days to comment on the new plan. These procedures will apply also
to all regulatory plan revisions.
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OUTLINE OF RESPONSIBILITY
Air Quality
Data From/
States /
Regional
Of fi ces
ther
AQCR's
RO
Notified
of
Problem
Adequate
Progress
No Action
Within
Normal
Limits
iRO Review For i
[Potential j
Problem
Validate
air
uali
aag/ p
Data
Revised
Report to
OAQPS Results
for Report to
Administrator
RO
nvastigate
nd resolve
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Enclosure #1
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Enclosure #1
Additional Technical Publications to Assist in Regional Office
Investigation of the Need for Plan Revisions
1. AP 78: Guide for Air Pollution Episode Avoidance
2. AP 98: Air Quality Surveillance Networks
i
3. APTD 0736: Field Operators Guide for Automatic Air Monitoring Equipment
4. APTD 1085: Air Quality Data Handling System Users Manual
5. APTD 1347: Guidelines for Technical Services of a State Air Pollution
Control Agency
6. EPA-RA-73-028c: Guidelines for Development of a Quality Assurance
Program - Photochemical Oxidants
7. EPA-RA-73-028c: Guidelines for Development of a Quality Assurance
Program - Carbon Monoxide
4
8. EPA-RA-73-028c: Guidelines for Development of a Quality Assurance
Program - Suspended Particulate Matter
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MDAD
NADB Reports
a. NEDS
SAROAD
quarterly reports
b. Quarterly summary ststisties air quality data
c. National Emission Report (Annual)
d. Site file directory - air quality monitoring (annual)
e. ISO/direct request using standard computer program
MRB
a.
b.
Trends Report (Quarterly)
Special analysis reports (quarterly)
Reporting high measurement regions
DSSE - (CDS/KAPINS)
a. Semiannual questionnaire used to update CDS
b. Region by region statistical output - data"summary by city/county/
region/state, etc. (percent in compliance, etc.)
c. Source ID report - Basic Source Data
d. ' Future schedule summary
e. Geographic locations
f. Action summary report
g. Status summary report
h. Source action summary
j. Overdue action report
GAD'
Must be some reporting but '.-liable to identify specific items
SIB
a. Guidelines for dcmer ^.i.-j the need for a plan revision
b. RTI manual for P.I'iS analysis
C. Protocol for submitting new data and results of PRMS to R.O.
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Enclosure #2
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ENVIRONMENTAL
[PROTECTION ORDER
AGENCY
I
1270.5
October 15, 1973
DELEGATIONS OF AUTHORITY - AIR AND WATER PROGRAMS
DELEGATION OF AUTHORITY TO REQUEST STATES TO
REVISE STATE IMPLEMENTATION FLANS
1. PURPOSE. This Order delegates to the Regional Administrators the
authority to request States to revise State Implementation Plans under
Section 110(a)(2)(H)(ii) of the Clean Air Act.
2. BACKGROUND. Section 110(a)(2)(H)(ii) of the Clean Air Act provides
for the revision of State Implementation Plans (SIP's)•"whenever the
Administrator finds on the basis of information available to him that the
plan is substantially inadequate to achieve the national ambient air
quality primary or secondary standard which it implements." In view of
the emphases on utilizing regional offices in supervising the SIP's, a
delegation of authority to the Regional Administrators uo request the
revisions is in order.
3. DELEGATION. The Regional Administrators are delegated authority to
perform the responsibilities indicated above within their respective
regions.
4. LIMITATIONS.
a. Revisions will be requested only when such revisions are clearly
necessary.
•»
b. Where the requested revision would affect emission control
regulations significantly, or the enforcement thereof, Regional Admin-
istrators should obtain the concurrence of the Assistant Administrator
for Air and Water Programs and the Assistant Administrator for Enforce-
ment and General Counsel.
c. Where the requested revision would have significant national
policy implications or would establish a significant precedent, the
concurrence of the aforesaid Assistant Administrators is required.
Dist: Directives Distribution initiated by: AF
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1270.5
October 15, 1973
d. Insofar as other revisions are concerned, Regional Administrators
should simply notify the two Assistant Administrators of requests made.
e. This authority may not be redeles
Russell E. Train
Administrator
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Enclosure #3
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Enclosure #3
Guidelines on Ambient Trend Monitoring
Monitoring and Data Analysis Division
1. General guidelines for Regional Office monitoring programs
PURPOSE: General summary of existing ambient trend monitoring
guidelines
2. Guidelines for validation of Air Quality Data
PURPOSE: Steps to insure valid data
3. Guidelines on interpretation of Air Quality Data as it relates to NAAQS.
PURPOSE: Answer questions on how NAAQS and Air Quality is related
4. Guidelines for network design and instrument siting
PURPOSE: Network design and instrument siting criteria
5. Guidelines for selection of air monitoring instruments.
PURPOSE: Selection of instruments
6. Guidelines for evaluation of air quality trends
PURPOSE: Trend evaluation
7. Guidelines for the evaluation of air quality data
PURPOSE: Evaluation methodology
8. Guidelines for complex source monitoring
9. Evaluation of SIP monitoring requirements
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Enclosure #4
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Enclosure #
CATALOG OF PROGRAMS as of OG/01/73
APRAC - A short-term Urban Diffusion Model that calculates the
automotive contribution to Carbon Monoxide. The model
was developed by Stanford Research Institute (SRI).
A 120 page manual is available on the model.
HIWA'.Y -
PTMAX -
PTD/S
PTMTP
READT
A model that calculates a pollutant concentration
in the vicinity of a roadway. The model is
self-documenting.
An interactive program which performs nn analysis of
the maximum, short-term concentration from a point
source as a function of stability and wind speed.
An interactive program which computes short-term
concentrations downwind from a point source at
distances specified by the user.
An interactive program which computes, at multiple
receptors, short term concentrations resulting from
multiple point sources.
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